EU Critical Raw Materials Act

The EU Critical Raw Materials Act (CRMA), which entered into force in May 2024, establishes the European Union's most comprehensive framework for strategic material supply security. It sets binding 2030 targets for domestic extraction, processing, and recycling, caps import concentration from single countries, fast-tracks permitting for strategic projects, and mandates supply chain audits for large companies. Germanium is explicitly listed as a strategic raw material subject to all CRMA provisions.

May 2024

CRMA Entered Into Force

Strategic Raw Materials Listed

10/40/25

2030 Targets: Extraction/Processing/Recycling %

65%

Max Single-Country Import Share Allowed

CRMA Overview: What It Is and Why It Was Passed

The EU Critical Raw Materials Act is a regulation passed by the European Parliament and Council, proposed by the European Commission in March 2023 and entering into force in May 2024. It was the EU's direct policy response to two simultaneous vulnerabilities exposed in 2022-2023: the energy dependency on Russian gas (addressed separately by REPowerEU) and the critical mineral dependency on China, brought into sharp relief by the August 2023 germanium and gallium export controls.

The CRMA establishes a list of "strategic raw materials" - materials deemed critical for the green and digital transitions and for defense and space applications - and creates a framework for reducing supply concentration and building EU domestic capacity. The regulation is directly binding on EU member states and on large companies operating in the EU, making it the most binding critical mineral supply security framework adopted by any Western jurisdiction.

Strategic vs. Critical Materials Under CRMA

The CRMA distinguishes between "strategic raw materials" (34 materials facing supply concentration and green/digital/defense importance) and the broader "critical raw materials" list (50+ materials with supply risk and economic importance). Germanium appears on the strategic raw materials list - the more restrictive category that triggers the binding 2030 targets and the single-country import cap. Both lists are subject to regular review and update.

Germanium and the Strategic Materials List

Germanium was included on the CRMA's strategic raw materials list based on three criteria: its critical importance for defense and space applications (infrared optics, space solar cells), its role in digital infrastructure (fiber optic networks, SiGe transistors), and its extreme supply concentration in China. The EU assessed that germanium's supply risk profile was among the highest of any material in the EU's industrial base.

At the time the CRMA was under development, the EU was already importing approximately 72% of its germanium needs from China. This single-country dependency directly triggered the CRMA's import concentration cap, which limits single-country import shares to 65% of EU consumption by 2030. Achieving compliance with this cap for germanium requires the EU to either develop domestic EU production capacity, secure supply from allied nations (primarily Belgium's Umicore from non-Chinese feedstocks), or reduce germanium consumption through substitution.

2030 Targets: Current State vs. Required Progress

The CRMA's 2030 targets represent substantial ambitions from the current state of EU domestic critical mineral supply. The chart below compares the EU's estimated current performance against the required 2030 targets for germanium across the three metrics.

EU Germanium Supply: Current State vs. CRMA 2030 Targets (% of EU Consumption)

Source: European Commission CRMA impact assessment; Roskill; author estimates

The gap between current performance and 2030 targets is substantial across all three metrics, but the single-country import cap is the most immediately challenging. At current import patterns, the EU would need to reduce Chinese-sourced germanium from approximately 72% to 65% of consumption - a reduction that requires either increased non-Chinese supply or reduced Chinese imports. Given the current supply constraints, this will require significant investment in European refining capacity and allied-nation supply agreements.

Key CRMA Provisions and Germanium Impact

Key EU Critical Raw Materials Act Provisions and Their Specific Germanium Implications

Key Provision	Description	Germanium Impact
2030 Domestic Extraction Target	At least 10% of EU annual consumption to be extracted within EU	Requires EU-based Ge recovery from domestic zinc operations
2030 Domestic Processing Target	At least 40% of EU consumption to be processed within EU	Expands Umicore/Boliden processing mandates; may require new facilities
2030 Recycling Target	At least 25% of EU consumption from recycled end-of-life material	Drives investment in Ge recovery from fiber optic and semiconductor scrap
Single-country import cap	No more than 65% of EU consumption of any strategic material from one country	Directly triggers action since China provides ~72% of EU Ge currently
Strategic project fast-tracking	Permitting for CRMA-recognized strategic projects capped at 27 months (extraction), 15 months (processing)	Accelerates timeline for new EU Ge refining projects vs. standard permitting
Supply chain stress testing	Large companies must conduct supply chain audits for strategic materials	Forces disclosure of Ge supply concentration; incentivizes buyer diversification

Source: EU Critical Raw Materials Act (Regulation 2024/1252); European Commission

Germanium in the Context of Strategic Materials

Germanium is one of 34 strategic raw materials under the CRMA, many of which face similar supply concentration challenges. The table below shows selected strategic materials and their relationship to the germanium supply challenge, illustrating that the EU faces a systemic critical mineral dependency problem rather than an isolated germanium issue.

Selected EU Strategic Raw Materials with Chinese Supply Concentration

Strategic Raw Material	EU Import Dependency	Top Supplier	Link to Germanium
Germanium	100%	China (~60%)	Direct - primary subject
Gallium	100%	China (~80%)	Co-controlled with Ge in China policy
Rare Earth Elements	100%	China (~70%)	Supply chain concentration parallel
Graphite (battery grade)	100%	China (~65%)	Parallel export control target
Indium	>80%	China (~55%)	Similar byproduct supply structure
Coking Coal	45%	Russia/Australia	Coal fly ash potential Ge feedstock

Source: EU CRMA Impact Assessment; USGS Mineral Commodity Summaries 2024; BGS

Implementation and Key Challenges

The CRMA's implementation faces several practical challenges. The permitting fast-track provisions - which cap processing project permitting at 15 months and extraction at 27 months - will require member states to significantly accelerate their existing regulatory processes. Environmental and community consultation requirements under national law in many EU member states often extend well beyond these caps, creating legal tensions between CRMA obligations and domestic regulatory frameworks.

The supply chain stress testing requirement, which obligates large companies to audit and disclose their critical material supply chains, is expected to catalyze significant private sector investment in germanium supply diversification. Companies that discover concentrated Chinese germanium dependency in their audits face regulatory pressure to address it, creating commercial demand for non-Chinese germanium that will help justify investment in alternative supply.

2030 Target Feasibility

Independent assessments suggest that the CRMA's 2030 domestic processing target of 40% is achievable for germanium given Umicore's existing capacity and planned expansions. However, the domestic extraction target of 10% is more challenging, as EU zinc mining and smelting capacity is limited. The recycling target of 25% is technically feasible but requires rapid scaling of germanium recovery from optical fiber and electronics waste streams that currently have limited collection and processing infrastructure.

Frequently Asked Questions

Yes. Umicore's Hoboken facility in Belgium is within the EU, and germanium processed there counts toward EU domestic processing targets regardless of where the germanium feedstock originates. This is an important distinction: if Umicore imports zinc concentrate from outside the EU and recovers germanium in Belgium, that germanium counts as domestically processed for CRMA purposes. Only extraction from EU-based ore deposits is subject to the more stringent extraction target.

The CRMA and China's export controls are interacting in a reinforcing way. China's controls reduce available Chinese supply to EU buyers, creating urgency to develop non-Chinese sources. The CRMA provides the regulatory framework and permitting acceleration to enable that development. Together, the two policies are driving EU investment in domestic and allied-nation germanium supply that would likely not occur under purely commercial incentives.

The CRMA does not itself provide grants or direct funding. It creates the regulatory framework for faster permitting and sets targets. However, it operates in conjunction with the European Strategic Investments Fund (InvestEU), Horizon Europe research funding, and member-state industrial policy programs that can provide direct financial support for CRMA strategic projects. The "strategic project" designation under CRMA facilitates access to these funding streams.

The CRMA does not specify penalties for member states or the EU collectively if the 2030 targets are missed. The targets are binding in the sense that they establish legal obligations to pursue achievement, but enforcement is primarily through Commission monitoring, reporting requirements, and political pressure rather than financial sanctions. The more consequential risk is continued supply vulnerability: if targets are not met, the EU remains exposed to Chinese mineral supply disruptions beyond 2030.